An EMS can and should be designed with pollution
prevention in mind; i.e., eliminating pollution at the source. This means
incorporating practical tools into the elements of the EMS, as is described
in the table below from Research Triangle Institute found at Pollution Prevention Connection with ISO 14001. RTI has made available online
the Environmental Management
Systems Evaluation Tool, an interactive guide to integrating P2 into an
EMS. It provides a thorough review with a report indicating how well P2 integration
is in place, along with recommendations for improvement of an EMS to achieve
results beyond what is required by ISO 14001.

2. Environmental Requirements and Voluntary Undertakings

Link all identified environmental aspects to the internal sources or
activities that affect them.

Forecast environmental regulations and other external requirements and
brainstorm P2 solutions that can mitigate or avoid them.

Identify process and product improvement requirements that will be necessary
for competitiveness and develop environmental performance goals for them.

Identify regulatory and other programs that encourage pollution prevention
and learn how to cooperate with them for business and environmental advantage.

Ensure all plans for compliance support also include components for
pollution prevention related to compliance.

3. Objectives and Targets

Establish quantifiable and readily-measured goals for resource efficiency, toxics reduction and waste reduction at
the process level. Have process workers design indicators that they can measure and manage themselves in real time.

Establish objectives and targets for improving the management accounting process for assigning all compliance and environmental costs to responsible activities.

Develop an index for the environmental impact of products and services and establish goals for improving the index
performance.

Create knowledge improvement targets to ensure that effective P2 solutions from around the world are not overlooked.

4. Structure, Responsibilities and Resources

Make all process supervisors and department managers
responsible for the environmental performance of their units.
Minimize the number of dedicated environmental staff.

Use full-cost accounting to link P2 performance to the
budget and to employee compensation rules.

Include P2 performance in job descriptions and employee
evaluations.

If feasible, rotate staff between compliance and production
responsibilities.

5. Operational Control

Have activity workers produce simple process diagrams that
are readily available and have basic statistics on wastes and
emissions at every step.

Provide simple procedures for measuring and reporting on
process or product environmental impact that give the
employees feedback in real time (these might include
process controls such as water sub meters, run charts on
waste generation or water use, etc.)

Establish a procedure to ensure that the P2 Hierarchy is
followed consistently in all decisions regarding environmental
performance.

When documented procedures for activities are required
because their absence could cause significant environmental
impacts, establish additional procedures to ensure that
these activities are given highest priority for P2 action.

Have a procedure for regularly reporting on P2 progress to
senior management.

6. Corrective and Preventive Action and Emergency
Procedures

Apply the P2 Hierarchy in all corrective and preventive
actions.

Use a hazard analysis to identify potential emergency
situations and make the related activities a priority for P2.

4. Training, Awareness and Competence

Provide modules on P2 in all existing training.

For staff with significant environmental aspects to manage,
ensure that required EMS training includes detailed P2
methods and solutions.

Give key staff training in how to use the Internet to tap into
the local and global network of practical P2 solutions.

Use case study data in training to show the real business
benefits of P2.

5.Organizational Decision-making and Planning

Use life-cycle analysis to identify environmental threats and
opportunities up and down the product or service chain that
could affect business performance, from natural resource
harvesters to product disposers.

Develop proactive strategies to minimize environmental risks
in the product or service chain.

But the opportunity for improving P2 performance does exist with a well-executed EMS. A preliminary University of Oregon study indicates that firms with ISO 14001 certification have reduced emissions compared to a control group of firms not certified. Several US States are moving to explicitly integrate EMS and P2 in their assistance to small and medium sized enterprises. A portion of the article "Pollution Prevention: The Cost-Effective Approach to ISO 14001 Compliance" provides guidance on how to incorporate P2 principles into an EMS. It appears that facilities that have pollution prevention plans in place have demonstrated improved performance to facilities without such plans. The suggestion has been made in a study [pdf] of the National Database on Environmental Management Systems (NDEMS) that a similar differentiation of performance would occur with EMS implementation by enterprises such as SMEs.

The Western Sustainability and Pollution Prevention Network (WSPPN) is a cooperative alliance of pollution prevention (P2) programs throughout EPA Region 9 (Arizona, California, Hawaii, Nevada, Trust Territories, and Tribal Lands). The network serves as a technical resource for regional P2 issues through researching, consolidating, and disseminating P2 information. WSPPN was established in 1997 and is run as a service provided by The Business Environmental Program (BEP) at the University of Nevada, Reno.